The ability of banks to sell the loans they originate is a core element in the development and sustainability of a nationwide lending market.  Recent legal developments threaten to undermine this ability, jeopardizing the foundation of a U.S. nationwide loan market and the core lending activities of banks.

A long-settled … Read More

As we head into the July 4th holiday and the heart of summer approaches, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations, resignations and expiring terms.  The first slide summarizes the state of play for the agencies’ principals; … Read More

Financial services regulatory reform in 2018 continues to evolve.  For those of you who have been thinking you might catch up over the summer lull, here is the summer beach read edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, … Read More

Today, the Federal Reserve and FDIC issued and invited comments on proposed guidance on the 2019 and subsequent submissions of the U.S. G-SIBs’ 165(d) resolution plans. The Proposed Guidance is available here.

The Proposed Guidance is largely similar to the guidance issued by the Agencies in April 2016, with … Read More

Not enough attention has been paid to the FFIEC’s policy announcement on enforcement which is, we hope, the first step toward fundamental change.  The Policy Statement on Interagency Notification of Formal Enforcement Actions rescinds a 1997 policy statement and addresses the need for coordination in enforcement actions among the Board … Read More

Our visual memorandum here describes the key changes the Bipartisan Banking Act makes to the regulation of banking organizations. It is color coded for those who want to look only at the changes that affect their own organization.

The House is expected to pass the Economic Growth, Regulatory Relief and … Read More

As mid-year 2018 approaches, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations and resignations and expiring terms.  The first slide summaries the state of play for the principals, and the later slides provide a deeper dive on an agency-by-agency … Read More

The increased emphasis by the prudential banking agencies on recovery planning is evidenced by the Comptroller’s recent publication of a new recovery planning module for the Comptroller’s Handbook.  The addition of this module to the handbook flows from the OCC’s previously published guidelines[1] on recovery planning.[2] Recovery planning … Read More